Friends of Grasslands

supporting native grassy ecosystems

PO Box 440
Jamison Centre
Macquarie ACT 2614


NSW Threatened Species Scientific Committee
PO Box 1967
Hurstville NSW 2220


Dear Sir/Madam

Proposed Critically Endangered Ecological Community listing:
Werriwa Tablelands Cool Temperate Grassy Woodland in the South Eastern Highlands and South East Corner Bioregions

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and its members include professional scientists, landowners, land managers and interested members of the public.

FOG broadly endorses the proposal to list Werriwa Tableland Cool Temperate Grassy Woodland in the South Eastern Highlands Bioregion as a CRITICALLY ENDANGERED ECOLOGICAL COMMUNITY in Part 1 of Schedule 2.

FOG proposes that this community be renamed to “Southern Tableland Cool Wet Temperate Grassy Woodland” to distinguish it from the preliminary listed Monaro Tableland Cool Temperate Grassy Woodland (which accordingly should be renamed “Southern Tableland Cool Dry Temperate Grassy Woodland”). Our reasons for doing so are:

FOG also has suggestions about addition of a number of technical details that, if adopted, will make for a stronger, more robust determination for this critically endangered community, as follows.

Spelling/taxonomic error

Change this in the following section:

Section 1.1 – Change “Convolvulus erubescens” to “Convolvulus angustissimus

Section 1.1

The species list in this section is representative of high-quality remnants, but does not necessarily reflect degraded examples where the groundlayer has been disturbed by overgrazing or other disturbances. Lower quality examples consistent with the Werriwa Tableland Cool Temperate Grassy Woodland commonly have the following species, which should be reflected in the species list in section 1.1 of the preliminary determination:

Rytidosperma duttoniana, Gonocarpus tetragynus, Austrostipa densiflora, Epilobium billardierianum ssp. cinereum, Rytidosperma caespitosum, Rytidosperma leave, Epilobium billardierianum ssp. billardierianum, Euchiton sphaericus (as in Non-forest Ecosystem 152 and Non-forest/Forest Ecosystem 153 in Thomas et al., (2000)) and Einadia nutans, Poa labillardierei, Rytidosperma pilosum, Rytidosperma racemosum (as in community u78 in Armstrong et al. (2013)).

Additionally, the eucalypts Eucalyptus aggregata and E. ovata occur in remnants consistent with the Werriwa Tableland Cool Temperate Grassy Woodland. The vulnerable E. aggregata is listed as a component of the related Non-forest Ecosystem 152 of Thomas et al., (2000) and in related communities in Armstrong et al. (2013). Although apparently not sampled in plots in related communities in either Thomas et al., (2000) or Armstrong et al. (2013), E. ovata is known from communities consistent with Werriwa Tableland Cool Temperate Grassy Woodland. The preliminary determination for Monaro Tableland Cool Temperate Grassy Woodland (Section 4.5) refers to communities characterised by the co-dominance of E. pauciflora with E. aggregata or E. ovata in warmer areas with relatively unimpeded drainage. This type of commonly encountered within communities consistent with Werriwa Tableland Cool Temperate Grassy Woodland.

The woody species, Kunzea ericoides (which is listed as an invasive native species by Southeast Local Land Services ( and Kunzea parvifolia also commonly occur in remnants consistent with the Werriwa Tableland Cool Temperate Grassy Woodland. Thus the aforementioned species, Eucalyptus aggregata, E. ovata, Kunzea ericoides and K. parvifolia should all be included on the list in Section 1.1.

Failure to include species from lower quality examples of the community in section 1.1 will result in a failure to protect those remnants of the community that are not in a high quality state. It needs to be noted that plot samples collected from communities for subsequent vegetation analysis are almost invariably taken from sites that are representative of a supposed characteristic state for that community and thus are rarely collected from poorer samples. Resultant vegetation classifications are therefore reflective of that bias.

A full list of species that should be added to Section 1.1 (including species from degraded remnants and shrubs species not currently on the list is as follows:

Austrostipa densiflora

Poa labillardierei

Rytidosperma caespitosum

Rytidosperma duttoniana

Rytidosperma leave

Rytidosperma pilosum

Rytidosperma racemosum

Einadia nutans

Epilobium billardierianum subsp. billardierianum

Epilobium billardierianum subsp. cinereum

Euchiton sphaericus

Gonocarpus tetragynus

Eucalyptus aggregata

Eucalyptus ovata

Kunzea ericoides

Eucalyptus parvifolia

Section 4.1

The sentence that begins “The ground stratum is typically dominated by Themeda triandra ...” should be reworded to read “The ground stratum of highly intact remnants is typically dominated by Themeda triandra ...”.

This should then be followed by a sentence that reads “The ground stratum of poorer quality remnants may be composed of the some of the following grasses, either as monocultures or mixtures of one or more, usually several of the following grass species: Aristida ramosa, Austrostipa bigeniculata, Austrostipa densiflora, Bothriochloa macra, Elymus scaber, Microlaena stipoides var. stipoides, Panicum effusum, Poa labillardierei, Poa sieberiana, Rytidosperma caespitosum, Rytidosperma duttoniana, Rytidosperma leave, Rytidosperma pilosum, Rytidosperma racemosum, with or without Themeda triandra, and with some of the more grazing-tolerant forb species listed in Section 1.1 present, along with the following: Einadia nutans, Epilobium billardierianum subsp. billardierianum, Epilobium billardierianum subsp. cinereum, Euchiton sphaericus and Gonocarpus tetragynus.

This section should also include reference to Eucalyptus aggregata, E. ovata, Kunzea ericoides and K. parvifolia. The two eucalypts occur as co-dominants or sub-dominants in the community and the two Kunzea species either occur as isolated specimens or occasionally in dense shrublands where disturbance events have facilitated their proliferation.

Section 4.2

This paragraph needs reference to the occurrences of the community in the upper catchment of the Shoalhaven River, to distinguish this community from the general range of the Monaro Tableland Cool Temperate Grassy Woodland.

Section 3.1.8

This section should include the following exotic invasive species: Phalaris aquatica, Dactylis glomerata and Festuca spp. as other dominant invasive species in the Werriwa Tableland Cool Temperate Grassy Woodland.

Section 4.11

Include in this section the following threatened flora and fauna species:

Eucalyptus aggregate

Petroica boodang

Petroica phoenicea

Artamus cyanopterus

Yours sincerely


Geoff Robertson

17 October 2018


Armstrong RC, Turner KD, McDougall KL, Rehwinkel R, Crooks JL (2013) Plant communities of the upper Murrumbidgee catchment in New South Wales and the Australian Capital Territory, Cunninghamia 13, 125–265.

Thomas, V.,  Gellie, N., and  Harrison, T. (2000) Forest Ecosystem Classification and Mapping for the Southern CRA Region. Volume II  Appendices.  NSW National Parks and Wildlife Service, Southern Directorate. A report undertaken for the NSW CRA/RFA Steering Committee, Project Number NS 08EH